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Accordingly, the Distributions, as payments of money in respect of the Partners' interests in the Limited Partnership, are financial services under paragraph (f) …. When the Partnership provides the payment of a Distribution to a Partner, the Partnership is making … an exempt supply … unless the supply is zero-rated …. ...

However, there is no time limitation for assessing the following penalties: • the 6% penalty assessed under section 280; • the failure-to-file penalty under section 280.1; • the penalty for false statements and omissions under section 285; and • the third party penalty under section 285.1. ...

CRA responded: [T]he formula outlined in paragraph 254(2)(i) … makes reference to the “total consideration” … described in paragraph 254(2)(c) … [as] the sum of the consideration payable for the housing itself (that is, the purchase price of $250,000) and the consideration payable for any other taxable supply of an interest in the housing (that is, the assignment fee of $150,000). ... A [instead] were not a builder, his assignment of the agreement of purchase and sale would be an exempt supply … and the consideration for the exempt assignment would not be included in determining the “total consideration” as described in paragraph 254(2)(c). … ...

See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. V, No. 3, pp. 21-23 (April 1991), at p. 22., which states in respect of “Intercorporate Transactions” (in part): … [A]s an administrative concession, Revenue Canada stated that it would not apply the anti-avoidance rule in section 155 to any of the transactions between the various corporations, in order that the transactions could be completed for nil or nominal consideration. ...

T2059 Election on Disposition of Property by a Taxpayer to a Canadian Partnership-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) Filing instructions (different where co-ownership) Mail one copy of this election and related schedules (as specified), completed by the transferor as follows: – to the tax centre of the transferor – on or before the earliest date on which any party to the election has to file an income tax return for the tax year in which the transaction occurred (due date). This due date must consider any election under subsection 25(1) or 99(2) – separately from any other return • When many transferors elect to transfer the same property (co-ownership) or many members of the same partnership elect to transfer their partnership interests, the elections will be processed together and should be filed: – to the tax centre of the transferee – on or before the due date – by a designated transferor to file all of the completed forms for each transferor, together with a list of all of the electing transferors. This list should contain the name, address and social insurance, trust account or business number of each transferor and of each member of the transferee – separately from any other return ...

The maximum … claim using … [this] method is $400 (200 working days) per individual. Eligibility … Each individual working from home who meets the eligibility criteria can use the temporary flat rate method …. This means multiple people working from the same home can each make a claim. … You do not have to: calculate the size of your work space keep supporting documents … Your employer does not have to … complete and sign Form T2200S or Form T2200 Days that can be counted … [include] days you worked part-time hours from home This method can only be used for the 2020 tax year. ...

. … There are no provisions … to exempt the supply of paramedical services. … The fact that a paramedic may perform certain services on the delegated authority of a physician does not change the nature of the supply. ...

Example of application to services provided under active direction of sub 2.69 … Example 3 – Central paymaster rules Corporation A provides services to …[its subsidiary] Corporation B … of a type that could reasonably be expected to be performed by employees of the Corporation B in the ordinary course of its business. In this regard, Employees of Corporation A report to a permanent establishment of Corporation B, receive direction from Corporation B’s corporate structure, and all or substantially all of the Employees’ economic activity is for the benefit of Corporation B. … For the purposes of Part IV of the Regulations the salaries and wages of Corporation A’s Employees would be attributed to Corporation B’s salaries and wages paid in the year. ...

The term “other body established by a government” is also found in other provisions …. ... Discussion of Category 1 An “other body established by a government” includes a body that a government creates in legislation (i.e., through statute and subordinate legislation such as regulations and Orders-in-Council) … [e.g.] the Ontario Energy Board was created under the Ontario Energy Board Act …. It should be noted that this category does not include a body that is incorporated pursuant to-the authority of a statute that provides the legal basis for and a scheme for incorporation e.g., … the Canada Corporations Act …. ...

Example 3 – Imported supply of a service During a claim period, a non-registrant PSB resident in Ontario is the recipient of a taxable supply of consulting services made outside Canada by a non-registrant supplier resident in the United States for $10,000. ... The PSB self-assesses the amount of $500 ($10,000 × 5%) on Form GST59, GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges. ... The PSB self-assesses the amount of $800 ($10,000 × 8%) on form GST59, GST/HST Return for Imported Taxable Supplies and Qualifying Consideration. ...